Karl Meyer has been a stakeholder, intervenor, and Fish and Aquatics Studies team member in the Federal Energy Regulatory Commission relicensing proceeding for the Northfield Mountain Pumped Storage Project since 2012. Meyer is a member of the Society of Environmental Journalists.
The Massachusetts Department of Environmental Protection is accepting written comments on FirstLight's application for a new FERC license to run Northfield Mountain for another 50 years, until 5 p.m. on June 3. The agency encourages submissions by email to [email protected]. (You must include "FirstLight 401 WQC" in the subject line.)
GREENFIELD, MASS.-Dear Vermont and New Hampshire: Thank you for not suing us here in the Commonwealth.
In 1798 - 226 years ago - we deprived you of migratory fish and a thriving Connecticut River when we built the first dam at Turners Falls to entirely block New England's Great River.
Instantly, your sustaining bounties of spring shad disappeared, along with smaller runs of herring, sea lamprey, eel, and salmon. And that's been the unending norm at fishing and village sites like Vernon, Brattleboro, Hinsdale, Chesterfield, Putney, Bellows Falls, and Walpole.
The dams, diversions, failed fish ladders, and the river-crippling pumped storage station licensed here in the ensuing centuries have continued massively robbing the river of life in the 20-mile corridor shared by Windham, Cheshire, and Franklin counties to this day. We've failed to share the Connecticut's common wealth.
Back in 1872, a landmark U.S. Supreme Court finding in Holyoke Company v. Lyman ruled dam owners must provide up- and downstream fish passage as a public trust. Yet you got no fish.
Worse, in 1968, Massachusetts granted Western Mass Electric Co. rights to build a giant river-vacuuming contraption: the Northfield Mountain Pumped Storage Station (NMPS).
It came on line in 1973 in the face of the Clean Water Act, and it has been regularly choking the Connecticut to a dead stop and erasing thousands of years of its natural history by reversing and inhaling miles of its ancient flow.
All this, while killing, by the millions, the fish and aquatic creatures it sucks in.
Thanks for your forbearance. Unfortunately, it seems you'll be needing more.
* * *
Last May, the Commonwealth of Massachusetts and the Division of Fisheries and Wildlife here signed a relicensing deal promising their full support of FirstLight Power's bid for a new federal license to run Northfield Mountain for another half-century.
The chaos and killing will continue - sorry.
Northfield is a giant, net-power-loss appliance, wholly dependent on and plugged into the grid to run suctioning turbines via the cheap, bulk megawatts FirstLight purchases. The river's miseries remain shackled to that buy-low/resell-high electricity resale model.
NMPS originally ran off the over-bloat of night juice produced by a newly completed Vermont Yankee nuclear plant.
But VY closed in 2014, leaving Northfield as primarily a gas guzzler, run on power from the grid that comes from the climate-killing natural gas that's the main source of today's electricity.
* * *
Shockingly, Northfield's profound lethal impacts on dozens of fish species in the 20-mile basin between the Vernon and Turners Falls dams remain largely uninvestigated.
A U.S. Fish & Wildlife Service study report in 2017 documents a fraction of that chaos and killing.
FirstLight's consultants had estimated that 14.9 million eggs and larvae of American shad - a vulnerable migratory species - were "entrained" (swallowed) by Northfield in 2016.
They contend that this mass evisceration resulted in losses of only 2,200 juvenile shad to the river system. However, the USFWS, applying a long-established study standard in its calculations, estimated river losses of 1.07 million juvenile shad for that season.
That's just for one species in this shared reach. Preposterously, no one has calculated Northfield's direct slaughter of juvenile and adult fish across the river's wide array of species.
* * *
If you're following the money, in 2019 FirstLight reported $158 million in Northfield profits, from a machine they'd reregistered into a Delaware tax shelter six months prior.
Parent-owned since 2016 by the Canadian government's global capital giant Public Sector Pension Investments (PSP), Northfield's suck and flush runs like an electric toilet - one that, by FirstLight's own admission, fully wastes 34% more energy than it later reproduces at peak resale profits.
It plugs in and slurps massive, hours-long slugs of river, pulling flows a mile uphill to its mountaintop reservoir "tank." That now-lifeless torrent is held, then the effluent is flushed through turbines to make resale electricity.
The water returns to its "bowl," the Connecticut River, which FirstLight describes as its "lower reservoir."
FirstLight pitches this resale juice as "clean" and "carbon free," though Northfield's lethality has been beefed-up as a gas-gulping climate killer since VY closed.
With its 34% waste, its all-it-can-eat aquatic buffet, and its apocalyptically reversing miles of flow, Northfield Mountain comprises this ecosystem's deadliest long-term outrage.
Thus, when you hear FirstLight claiming they can power up to 1 million homes for several hours, remember they've already burned through the virgin energy of 1.34 million homes - and a river - to do so.
And, once done, they must start consuming all over again.
* * *
Northfield's original FERC license expired in 2018, two years after PSP bought it. Since then, the company has realized and reinvested hundreds of millions in distant places far from this Valley, including New York, New Jersey, western Pennsylvania, Québec, and Ontario. FirstLight even opened its own $97 million lending bank a year ago.
Last spring, when the Commonwealth signed that FirstLight agreement, the state pledged to fully support the six-years-late, 50-year Federal Energy Regulatory Commission (FERC) license renewal bid - including a promise in writing to defend Northfield Mountain's river depredations against all federal and state Clean Water Act challenges.
The unprecedented state commitment to a foreign-owned entity here is now dependent on the Massachusetts Department of Environmental Protection issuing FirstLight a Water Quality Certificate under section 401 of the federal Clean Water Act to run Northfield Mountain on this interstate waterway, given its impacts.
The facility cannot be relicensed by FERC without that certificate.
The U.S. Fish & Wildlife Service and National Marine Fisheries Service are also collaborating. They signed the same FirstLight terms that will continue to suction, kill, reverse, and store yet more of the river.
Thus, it should be unsurprising that in FirstLight's FERC license proposal, you'll wait until at least 2034 before they build lifts to pass fish at Turners Falls - further slow-dancing fish passage that you, as residents of Vermont and New Hampshire, have been entitled to since 1872.
Of course, if the Commonwealth sanctions a new 50 years of pumped storage in this shared reach, the embedded catch-22 will still remain.
Once spawning-run shad finally pass Turners Falls, heading your way, Northfield will be waiting - and ready - to eat the vulnerable, newly-spawned young as it continues to suction in miles of flow, upstream and down.
* * *
As the Band-Aid solution for this river's grievous open wound, FirstLight has proposed seasonally deploying a 900-foot deflective net just upstream of Northfield's intake, instead of installing permanently anchored, replaceable screens.
Like the nets previously deployed for hatchery-derived salmon fry, these will clog with debris and repeatedly tear and fail in a river where flood surges and uprooted trees are increasingly common.
Those nets will be useless for pencil-thin baby shad - while their {3/8}-inch mesh will literally guarantee death rides for hundreds of millions of developing eggs, larvae, and young-of-the-year fish, spring through fall.
Sadly, the critical losses will again be yours.
This entrainment sacrifices the return of adult spawning-run shad and herring from the Atlantic to the open waters of New Hampshire and Vermont four and five years later. Fifty-one years after Northfield became a fish abattoir, FirstLight has decided that you must wait until 2032 before they'll even begin testing their red-herring net fix.
Back in 1967, Massachusetts, along with federal and state fish agencies, signed the "New England Cooperative Fisheries Restoration Agreement for the Connecticut River." It committed to restoring your full share of fish - with a key goal of passing 850,000 American shad beyond Turners Falls Dam and 750,000 passing Vernon Dam toward Bellows Falls.
But it warned of "fragmentary data" available for the proposed Northfield plant, posing "definite limitations to an anadromous fish restoration program" due to "the physical loss of eggs, larvae, and young fish of both anadromous and resident species, and an orientation problem for both upstream and downstream migrants attributed to pumping large volumes of water."
The Connecticut River's first successful fish lift had been installed at Holyoke Dam in 1955. Its simple design was passing hundreds of thousands of shad up to Turners Falls Dam by 1976, yet Co-op leaders here turned elsewhere for solutions.
They instead constructed three scaled-down ladders at Turners Falls, modeled on giant ladders on the Columbia River that passed huge runs of several salmon species, plus introduced shad.
Completed in 1980, the ladders here forced all migrants out of the river and into the alien flows of a 2-mile power canal to pass the dam. Confused and exhausted, your runs were basically barred and blocked here again.
After 44 years, out of the hundreds of thousands of shad arriving at Turners Falls annually, the average passage success rate is 5 fish in 100.
The Commonwealth again had licensed the crushing of Vermont's and New Hampshire's right to a living river.
* * *
Hardly indispensable to the day-to-day running of the power grid, no one noticed when Northfield shut down at the end of summer last year - and stayed offline through this January. A boatload of virgin energy got conserved, and its apocalyptic ecosystem-killing and flow-reversals ceased.
The bloated, bulk grid run by ISO-New England, a longtime cheerleading collaborator in Northfield's waste and killing, ran without a hiccup. And no one in New England spent their holidays shivering in candlelight.
The previous time Northfield was offline was for more than half a year, from May to November of 2010, when its tunnels got choked with the tons of accumulated muck and effluent that FirstLight was trying to flush from its reservoir.
After attempting to conceal the disaster, the EPA ordered FirstLight to "cease and desist" in its massive, ongoing Clean Water Act violations for dumping 40 to 50 truckloads of pollutants directly into the Connecticut for over 90 straight days.
Correspondingly, that spring, the always-dismal fish passage at Turners Falls experienced a mini-surge - skyrocketing 600% above the decade's limping averages - on a Connecticut River free of Northfield's daily assault.
* * *
Northfield is a monument to ecosystem destruction, a contraption built and dependent on daily waste and overkill, profiting internationally at the public and the river's expense here.
It's now up to the Commonwealth's Department of Environmental Protection to sanction and issue a new Water Quality (401 WQ) Certificate allowing FERC to relicense a new half-century of investor reward via this deadliest, most-alien, river-reversing appliance ever emplaced on the Connecticut River.
And it came online in Massachusetts a year after the federal Clean Water Act became law.
In a meeting this March 26, FirstLight and its state collaborators Massachusetts Fish & Wildlife and the Department of Conservation and Recreation, plus engineers from an outfit called Inter-Fluve, met behind closed doors here with our Department of Environmental Protection to smooth out any unforeseen bumps in the company's 50-year river deal.
Alas, even as a deeply impacted "neighboring jurisdiction" under the CWA, you were not invited.
It's as if you have no rights here. We haven't shared a living river. Again, apologies. And thank you for not suing us.
This Voices Viewpoint was submitted to The Commons.
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